PERMIT REVIEW SUMMARY

Permit Writer:	Clinton Gentry	Date:	May 14, 2019

Company Name:	Venture Oil and Gas Inc, Ford 8-5 Number 1 Tank Battery

Facility Location:	Well Road off of Smith CR 33B
Taylorsville, MS
31o 51’ 3.2” N
89o 19’ 55.99” W

Source Number:	2500-00096

County: 		Smith

PROJECT DESCRIPTION

The Venture Oil and Gas Inc., Ford 8-5 No. 1 Facility is classified as a crude petroleum and natural gas extraction site under SIC 1311 and NAICS 21111. This site is the newest of four wellheads located within the same field all under Venture’s control. 

Venture Oil and Gas Inc., has applied for a Permit to Construct and a Synthetic Minor Operating Permit for their Ford 8-5 No. 1 Facility located in Smith County, Mississippi. The Ford 8-5 No. 1 Facility is an oil and gas production facility containing the following emission points: one (1) control flare, one (1) pump engine, two (2) separators, one (1) heater treater, four (4) miscellaneous chemical tanks, four (4) oil and water tanks, and fugitives from equipment leaks and load out operations. Emissions from the separators, oil and water tanks, and the heater treater will be routed to the flare for control. For the entire facility, produced gas from the well will be used a fuel source except during periods of curtailment and startup in which case propane will be used to keep the flare pilot light operational. 

EMISSION SUMMARY

Maximum Uncontrolled Emissions vs. Proposed Allowable Emissions (in tons per year)	
	PM	SO2	NOx	CO	VOC	HAP (total)	
Uncontrolled	0.13	0.01	14.57	220.11	2493.10	53.65	
Controlled	1.24	0.00	22.43	76.53	55.46	1.58	

As shown in the table above, Venture has the potential to exceed the Prevention of Significant Deterioration (PSD) thresholds for Volatile Organic Compounds (VOCs) and the potential to exceed the Title V thresholds for VOCs, Carbon Monoxide (CO) and Hazardous Air Pollutants (HAPs). In order to qualify as a Synthetic Minor Source, Venture has opted to take limitations in the form of routing the produced gas to the process control flare in order to maintain controlled emissions below Title V thresholds. These thresholds are 100 tons per year (tpy) for VOCs and CO as well as 10 tpy and 25 tpy for individual and aggregate HAPs, respectively. 

APPLICABLE/PROPOSED PERMIT LIMITATIONS

For the entire facility, the permittee shall limit the emissions of VOC to no more than 95.0 tons per year for each consecutive 12-month period on a rolling basis. The permittee shall also limit the emissions of CO to no more than 95.0 tons per year for each consecutive 12-month period on a rolling basis. Furthermore, for the entire facility, the permittee shall limit the emissions of any individual HAP to no more than 9.0 tons per year and the emissions of all combined HAPs to no more than 24.0 tons per year for each consecutive 12-month period on a rolling basis. The permittee is also required to route all vented gas emissions to the control flare (Emission Point AA-001). The permittee is also required to comply with several work practice standards for the control flare in order to ensure that the vented gas emissions are controlled as efficiently as possible.

NEW SOURCE PERFOMANCE STANDARDS (NSPS)

Subpart JJJJ – Standards of Performance for Stationary Spark Ignition Internal Combustion Engines
This subpart applies to owners and operators of Spark Ignition (SI) Internal Combustion Engines (ICE) that commenced construction after 2006. This site utilizes a pre-2006 model engine and is therefore not subject to this subpart.

Subpart OOOOa – Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced after September 18, 2015
This subpart applies to onshore facilities including gas wells, centrifugal compressors, reciprocating compressors, pneumatic controllers, storage vessels with potential-to-emit VOC above six (6) tons per year, and sweetening units. Because those units are not at the site and the tanks emit less than six tons per year of VOC, these emission points are not subject to Subpart OOOO. However, this site will have an affected facility for the collection of fugitive emissions components at a well site. Therefore, this site is subject to all requirements applicable to fugitive emissions sources. 

Subpart Kb - Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984
This subpart applies to each storage vessel with a capacity greater than or equal to 75 cubic meters (m3) that is used to store volatile organic liquids (VOL) for which construction, reconstruction, or modification is commenced after July 23, 1984. As such, this facility is potentially subject to this subpart. However, according to § 60.110b(d)(4), these vessels are exempt because they are “[v]essels with a design capacity less than or equal to 1589.874 m3 used for petroleum or condensate stored, processed, or treated prior to custody transfer.”; therefore, these emissions points are not subject to this Subpart Kb.

MACT APPLICABILITY

Subpart HH – National Emission Standards for Hazardous Air Pollutants from Oil and Natural Gas Production Facilities
This subpart applies to owners and operators of glycol dehydration units located at natural gas production facilities which are major or area sources. This facility does not operate any glycol dehydration units and is therefore not subject to Subpart HH

Subpart HHH – National Emission Standards for Hazardous Air Pollutants from Natural Gas Transmission and Storage Facilities
This subpart applies to natural gas transmission and storage facilities located at a major source. This facility is defined as an area source and is therefore not subject to Subpart HHH.

Subpart ZZZZ - National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines
This subpart applies to owners and operators of any Reciprocating Internal Combustion Engines (RICE) located at a major or area source of HAP emissions. Emission Point AA-002 is classified as an “existing”, non-emergency, < 10 liter, Spark Ignition (SI), 4-Stroke Rich Burn (4SRB), 165 HP oil pump engine and therefore is subject to this subpart. 

PUBLIC PARTICIPATION

The 30-day public notice period began on June 13, 2019, with the publication of a notice in the Laurel Leader Call and ends July 15, 2019.

RECOMMENDATION

The staff has preliminarily decided to recommend issuance of the permit to the Mississippi Environmental Quality Permit Board as shown in the draft permit.  However, the staff recommendation to the Board will be made only after a thorough consideration of all public comments.